Process Safety Management (PSM)

The Process Safety Management (PSM) standard is overseen by OSHA under the following regulation:

Title 29 of the Code of Federal Regulations Part 1910 Section 119

Following a series of accidental releases of toxic, reactive, and flammable chemicals in various industries, OSHA published the proposed standard “Process Safety Management of Highly Hazardous Chemicals” on July 17, 1990. The standard is designed to ensure facilities safely manage the hazards associated with the use of highly hazardous chemicals. The Clean Air Act Amendments were enacted into law on November 15, 1990, which required the standard to include a list of highly hazardous chemicals and the following safety programs:

Applicability to PSM is based upon the amount of the hazardous chemical used in the process onsite.  Processes with quantities exceeding the listed threshold require the owner/operator to comply with the standard.

 PSM RMP Solutions can provide assistance in all aspects of the development and implementation of the Process Safety Management Program. The level of assistance may vary based on the needs of the client. The following are some examples: 

  • Management of Change: This could include simple reminders throughout your project or heavy involvement in the data collection process (contractor information, contractor liaison, etc.), documentation updates, and participating in the MOC Team.

  • Operating Procedures Review/Certification: PSM RMP Solutions could manage the review process by facilitating webex meetings and updating the documentation. As an alternative, an on-site meeting with facility personnel can also be arranged. 

  • Annual Compliance Meetings: PSM RMP Solutions will conduct an annual meeting to review the programs at your facility.  We understand that the programs are not always on the forefront of managers’ minds and may get overlooked. During this meeting, we will review the following:

    • Implementation Status of Recommendations (PHAs, Audits, & Seismic)

    • Operating Procedures (review/certification and update)

    • Contractor Paperwork

    • Incidents

    • Management of Changes

    • Emergency Response/Action Plan Implementation

  • Three Year Compliance Audits: It is the intent of the requirements to establish a procedure to evaluate the effectiveness of the process safety management programs by identifying deficiencies and ensuring corrective actions. PSM RMP Solutions offers to satisfy this requirement by conducting an on-site review of the PSM programs in place at the facility. In addition to a regulatory review of the written documentation, PSM RMP Solutions will evaluate the programs vs. the company’s ability to properly implement them, i.e., review records, interview employees, etc. A report will be generated as a result of the audit which will contain a list of deficiencies if any were found in the course of the audit.

  • Process Hazard Analysis: Initially and at least every five (5) years, a process hazard analysis shall be developed and revalidated, by a team meeting the requirements in subsection (e)(3) of the regulation, to assure that the analysis is consistent with the current process. PSM RMP Solutions will provide both a PHA Leader and scribe to assess the process. There are several methodologies permitted by the regulation, however, PSM RMP Solutions will utilize either the Hazard and Operability (HAZOP) analysis or What-If Question analysis depending on the facility needs.  Participation will be required by personnel that work on the system, i.e. a contractor (if one is used), in-house operators, management, etc.

  • Implementation Support: PSM RMP Solutions can provide support with the implementation of various aspects of the PSM program. For example, in the event of a chemical release, we can provide information over the phone regarding pertinent phone numbers, local & state reporting requirements, assistance with the completion of incident investigation forms, etc. As an alternative, we can participate in the incident investigation team and assist team members with determining the root cause and actions needed to prevent incident recurrence.

For additional information see the OSHA Process Safety Management Website